Transfer Pricing Insider
Volume 3, Issue 1
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Thomson Reuters: Implications of the Credit Crunch
for Intercompany Loans
Source: J. Harold McClure, Senior Manager ONESOURCE Transfer Pricing
This article notes the credit spreads on long-term AAA and BBB government debt over the 1994 – 2008 period. It considers how the tax director for a hypothetical U.S. subsidiary that had incurred an intercompany loan two years ago might have managed its transfer pricing exposure. It then considers a situation where the U.S. sub wishes to raise funds in today’s market through an additional intercompany loan.<Discover More>
Recent Indian Transfer Pricing Rulings - Robust
Documentation is the Key
Source: Partho Dasgupta, Deloitte Haskings & Sells in Delhi
This article reviews rulings in the past year that indicate, despite a late start, India's transfer pricing rules are developing in line with those of other more experienced jurisdictions. This article analyzes some of the key contentious issues that the Tribunal has addressed in various recent rulings. Most of the rules that emerge are very close to the international norms. <Discover More>
Customs Valuation Issues at the WCO...
and Coming to a Foreign Jurisdiction Near You
(Parts 1 and 2)
Source:Mark K. Neville, Jr. LL.M. NYU, is of counsel to DLA Piper in the firm's New York office, and serves as an adjunct professor at the University of California, Berkeley's Haas School of Business. He is the Journal's Customs & Trade correspondent and a member of the Board of Advisors.
This article discusses two of the more serious customs valuation issues—transfer pricing and royalties—that have been on the agenda for years and were discussed as recently as October 2008, with the Technical Committee on Customs Valuation (Technical Committee) of the WCO as the venue. <Discover More>
Tax Regimes in CIS Countries
Source: Douglas A. Townsend, Senior Advisor with the International Tax and Investment Center (ITIC) in the United Kingdom. Movlan Pashayev, Director of Tax and Legal Practice of PricewaterhouseCoopers in Azerbaijan. Sergey Bezborodov, Manager of International Tax Structuring with PricewaterhouseCoopers in Kazakhstan.
This article provides an overview of tax regimes in the former Soviet Union countries, including major areas for reform, the impact of European Partnership and Cooperation Agreements on CIS tax laws, and transfer pricing qualification. <Discover More>
A Model for Intercompany Factoring Arrangements
Source: J. Harold McClure, Senior Manager ONESOURCE Transfer Pricing
This article outlines a model for the determination of arm's-length discounts and demonstrates that the debate over the discounts often amounts to the appropriate determination of what is a reasonable expected return to the assets of a factoring entity. It proposes the use of the capital asset pricing model (CAPM) and discusses two intercompany factoring arrangements—one in FSA 200224003 and the agreement between Dell Marketing and Dell Receivables. <Discover More>
Effects of China's New Enterprise Income Tax Law on
Multinational Enterprises
Source: Yingchun Zhao, Professor and Director of Taxation Department at Shanghai Lixing University of Commerce, Shanghai. Michael Dong, Director of Taxation for Sega Holdings U.S.A, Inc., San Francisco.
This article discusses the new enterprise income tax law and how it does away with different tax treatment of domestic and international multinational enterprises. Uncertainties in the new rules on transfer pricing, contemporaneous documentation, thin capitalization, CFCs, and anti-avoidance have temporarily slowed capital investment in China.<Discover More>
Global Employment Organizations
Get a New Lease on Life
Source: Rachel Halpert, is Partner and Allyson Stoll, is Manager of the Metro New York Office of Ernst & Young, LLP
This article informs that GEOs are starting to see resurgence as a means to address risk, employer and employee compliance, and tax planning with international assignees. The increased control for companies does not come without costs. Tax issues include the creation of PEs, corporate deductions, transfer pricing, VAT, and social security programs. <Discover More>
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